Attention: Ms. Isabel McGann
10811 W. Collins Avenue
Lakewood, CO 80215-4498
Product: Trima Accel System
Date Received: January 21, 2009
Dear Ms. McGann:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA’s issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act’s requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health’s (CDRH’s) Office of Compliance. Also, please note the regulation entitled, ²Misbranding by reference to premarket notification² (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH’s Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638â€‘2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Basil Golding, M.D.
Division of Hematology
Office of Blood Research and Review
Center for Biologics
Evaluation and Research
Indications for Use
510(k) Number: BK090003
Device Name: Trima Accel System
Indications For Use:
The Trima Accel system is an automated blood cell separator intended for use in collecting blood components for later transfusion into patients.
Depending on the disposable tubing set used, the Trima Accel system may collect:
- Double ACD-A/AS-3 Red Blood Cells (leukocytes reduced or not leukoreduced)
or the following products alone or in combination:
- Platelets Pheresis (single, double, or triple units)
- Platelets Pheresis, Leukocytes Reduced (single, double, or triple units)
- Plasma and Plasma, Leukocytes Reduced
- ACD-A/AS-3 Red Blood Cells
- ACD-A/AS-3 Red Blood Cells, Leukocytes Reduced utilizing an integrated filter
The Trima Blood Component Sampling Assembly, which is either integrated into the disposable tubing sets or as an accessory for sterile connection, is intended to allow aseptic removal of a sample from the platelet bag for subsequent bacterial or other applicable testing. The Sampling Assembly does not have contact with blood fluids that are reinfused to a donor or patient.
- Adequate studies have not been performed to evaluate the quality of gamma irradiation or freezing of ACD-A/AS-3 red blood cells products (RBCs) collected with gravity drain leukoreduction process (TLR filter) on the Trima Accel system.
- Studies have not been performed to support gamma irradiation or freezing of ACD-A/AS-3 RBC’s collected with an integrated in-line RBC leukoreduction filter(s) (AutoRBC filter) on the Trima Accel system.
RBC’s collected on the Trima Accel system using the AutoRBC feature as either a single unit or double units, with continuous RBC leukoreduction, and stored in ACD-A/AS-3 for 42 days met the following acceptance criteria required by the FDA-CBER:
- 95% probability and a one-sided 95% confidence limit:
- the number of contaminating leukocytes per unit is less than 5 million.
- the recovery of RBCs after leukoreduction is greater than 85%.
- RBC hemolysis is less than 1.0%.
- 70% probability and a one-sided 95% confidence limit, recovery in the circulation of radiolabeled RBCs 24 hours after transfusion is greater than 75%, and the average recovery is greater than 75% with a standard deviation less than 9%.
The results of biochemical tests, ATP and Potassium failed to show with 95% confidence that greater than 95% of the products will be within 20% of the Control product. Results of ATP levels for Test for a single RBC collection were not significantly different from Control by a paired t test analysis (p-value = 0.80). Results of ATP levels for Test for double RBC collections were significantly better than Control by a paired t test analysis (two-sided p-value = 0.014). Results of Potassium levels for Test for a single RBC collection were significantly better than Control by a paired t test analysis (p-value = 0.0354). Results of Potassium levels for Test for double RBC collections were not significantly different from Control by a paired t test analysis (two-sided p-value = 0.566).
The pH at end of RBC shelf life showed with 95% probability and a two-sided 95% confidence limit, the difference in pH between Test and Control was less than or equal to 0.5 pH units. The clinical significance of secondary outcomes is unknown.